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Article 27 UK GDPR · the Netherlands

UK representative for Dutch companies

The Netherlands sells into Britain in a way that makes this obligation easy to miss: through fulfilment centres, dropshipping and platform storefronts, where the Dutch company never feels like the one facing the British customer. It usually is, in the sense that matters — it decides what data is collected and why.

The Autoriteit Persoonsgegevens has no British mandate

Your supervisory authority is the AP, and it supervises the Union. Britain has the ICO, which expects a representative established in the United Kingdom. Neither authority substitutes for the other and neither accepts a designation naming a company in the other's territory.

WHO IS THE CONTROLLERB.V. in the Netherlandsdecides the purposeUK fulfilmentprocessor onlyREP27 LTDrepresentative in Britain
The British market reached by Dutch sellers through fulfilment and platform storefronts
Who packs the box does not decide who the controller is.
Working out which party in a fulfilment chain carries the representative obligation
A logistics partner in Britain answers a different question from the ICO’s.

Fulfilment and dropshipping do not move the obligation

If a British customer buys from your storefront, your terms apply and your systems hold their order, the personal data is yours as controller — regardless of who packs the box. A UK fulfilment partner is a processor for logistics, not a representative for data protection, and its address in your notice answers a different question from the one the ICO is asking.

Platform sellers and the empty field

Dutch sellers on British marketplaces meet this as a compliance field rather than a legal letter. The field asks for a UK representative and is validated: an EU address is often rejected outright, and the listing is suppressed until something British is entered. That is the moment most of our Dutch clients appear, usually the same day.

Proof that survives a procurement check

A British buyer running vendor due diligence asks for the representative and then checks it. Ours resolves on a public register with a UK27 code, showing the mandate as live or expired at that moment. A signed PDF proves that a PDF was signed, which is a weaker answer than it sounds when a contract depends on it.

Wat er in de privacyverklaring komt

The paragraph belongs in your privacyverklaring, with the controller's details, and must name an entity established in the United Kingdom. We supply it in Dutch and in English. Your European text is untouched: a company established in the Netherlands needs no EU representative. Only the British line is added, and it carries REP27 LTD, its company number and its Suffolk address.

Who plays which role in a fulfilment model

Your B.V.Decides purpose and meansController — the obligation is yours
UK fulfilment centrePacks and ships on instructionProcessor — not a representative
MarketplaceController for its own purposesDoes not cover yours
Payment providerController for payment dataSeparate from your obligation
REP27 LTDAccepts the written mandateRepresentative under Article 27 UK GDPR

Platformverkopers en het lege veld

Dutch sellers usually meet this as a validated field in a seller account rather than as a letter. The field asks for a UK representative, and increasingly it refuses an address in the EEA outright. Until something British is entered the listing is suppressed, which turns a data protection question into a revenue question within a day. The designation and its verification code close the field, and the code stays checkable afterwards, which is what a platform audit looks for the second time round.

Questions from Dutch companies

We only sell through a UK marketplace. Are we still the controller?

For the data you receive and process about your buyers, yes. The marketplace is a controller for its own purposes, not a substitute for your obligations.

Is a UK fulfilment centre enough?

No. Logistics is processing on your behalf. A representative must accept the mandate in writing and be named in your privacy notice.

Heeft de AVG-vertegenwoordiger ook waarde in het VK?

No. The UK GDPR requires a representative established in the United Kingdom, and an EU one has no standing before the ICO.

How is the appointment evidenced?

A designation letter, a dated certificate and a verification code that resolves on our public register.

Appointed today, verifiable today

One annual fee, no charge per request. From €290 a year for the United Kingdom, €390 for the United Kingdom and the Union together.

How the UK service works Pricing

Read next

Do I need one at all?

The three-question test, and the exemptions that rarely apply.

What the ICO expects

Who writes, what they ask for, and how fast an answer is due.

Why one duty became two

What the end of the transition actually changed, and for whom.

Establishing who is the controller in a fulfilment chain with three parties
The warehouse packs the box. The obligation stays with whoever set the purpose.
The contact point a Dutch platform seller must publish for the British market
The seller account validates the field. An EEA address is refused.

Companies elsewhere, same obligation

What changes from one country to the next is not the rule but the route into it: the transfer basis, the regulator you already know, and how British customers reach you.

Selling into Britain from United States

The same rule, a different starting point.

Selling into Britain from Germany

The same rule, a different starting point.

What the ICO expects

The guide that matters most here.